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Home My WebLink About00-08279 "_." ~, II I _I ~,,,",,,=~.~'ok,'; MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) : NO. DO - J>:n? Co~l 't~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 800-990-9108 ,~"..~- . J~ ,~ I ~ "_1 ,. .....,-,...-.L AVl:SO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Race falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus Objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para listed. LLEVE ESTA DEMANDA A UN ABOGADO l:MMEDIATAMENTE, Sl: NO TIENE ABOGADO o SI NO TIENE EL DINEll.O SUFICl:ENTE DE PAGAll. TAL SERVICl:O, VAYA EN PERSONA 0 LLAKE POR TELEFONO A LA OFICl:NA CUYA Dl:RECCION SE ENCUENTRA ESCRl:TA ABAJO PARA AVERIGUAll. DONDE SE PUEDE CONSEGUl:R ASISTENCl:A LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 800-990-9108 ,,,- ~, ., I" NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt ohhis Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, UpOIll your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN Isl Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 - 1,1 -' ~ , . ~, 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Option One Mortgage Corporation Assignments of Record to: Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage LoanTrust 1999-BC4 Recording Date: Lodged for Recording 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and morcgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 313 Lamp Post Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Hampden COUNTY: Cumberland DATE EXECUTED: 5/21/99 DATE RECORDED: 5/26/99 BOOK: 1544 PAGE: 886 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums I~l" ,i ~ '~ ".t-'.! 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Option One Mortgage Corporation Assignments of Record to: Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 Recording Date: Lodged for Recording 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with PA.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 313 Lamp Post Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Hampden COUNTY: Cumberland DATE EXECUTED: 5/21/99 DATE RECORDED: 5/26/99 BOOK: 1544 PAGE: 886 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums ~ l 'ei i, ~'" secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 11/17/00: Principal of debt due and unpaid Interest at 10.99% * from 6/01/00 to 11/17/00 (the per diem interest accruing on this debt is $26.98 and that sum should be added each day after 11/17/00) $89,594.05 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) 4,561.25 250.00 280.00 Escrow OVerdraft/(Balance) (The monthly escrow on this account is $.01 and that sum should be added on the first of each month after 11/17/00) 1240.00 Late Charges (monthly late charge of $51.38 should be added on the fifteenth of each month after 11/17/00) 256.90 Corporate Advance 48.00 Property Inspection Appraisal Attorneys Fees (anticipated and actual to 5% of principal) 161.70 120.00 4.479.70 TOTAL $100,991.63 " .- ~" I L , *This is an Adjustable Rate Mortgage and the Interest Rate and Per Diem are subject to adjustment as more fully set forth in the Mortgage and Note 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $100,991.63 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ~ Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN PIECE OR PARCEL OF IJ\ND, WITH IMPROVEMENTS THEREON ERECTED, SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND,. STATE OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE SOUTHWESTEIlLY SIDE OF LAMP POST IJ\NE AT THE DIVIDING LINE EEnlEEN LOT NOS. 9 AND 10, BLOCK "H' OF THE HEREINAFTER MENTIONED PLlIN, WHICH POINT IS 627.23 FEET IN A NORTHWESTEIlLY DIRECTION FROM THE SOUTHWESTERLY CORNER OF CARRIAGE HOUSE DRIVE AND LAMP POST IJ\NE OF THE PLAN; THENCE BY SAID DIVIDING LINE SOUTH 35 DEGro:ES, 10 MINUTES WEST 113.27 FEET TO A POINT AT THE LINE OF LOT 13, BLOCK "H" OF THE PLlIN; THENCE ALONG LOTS NOS. 13 AND 12, NORTH 59 DEGREES, 30 MINUTES WEST 100.33 FEET TO THE DIVIDING LINE BEnlEEN LOTS NO.S 10 AND 11, BLOCK "H" OF THE PLlIN; THENCE BY SAID DIVIDING LINE NORTH 35 DEGro:ES, 10 MINUTES EAST 121.43 FEET TO A POINT ON THE SOUTHWESTEIlLY SIDE OF LAMP POST IJ\NE; THENCE BY SAME SOUTH 54 DEGro:ES, 50 MINUTES EAST 100 FEET TO A POINT AT THE DIVIDING LINE BEnlEEN LOTS NO.9 AND 10, BLOCK "H" OF THE PLlIN, THE PLACE OF BEGINNING. BEING ALL OF LOT NO. 10, BLOCK "H", PLlIN 4 OF PINE BROOK AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLlIN BOOK 15, PAGE 41. ,.,~>'"~~' ,. I' ''I1"~,i' e. September 05, 2000 OPTION ONE MORTGAGE OORPORATIO..... Carter Harrison 313 Lamppost Lane Camp Hill, PA 17011 Homeowners Name: Carter Harrison Property Address: 313 Lamp Post Lane, Hampden PA 17011 Loan Account No.: 169334-0 Original Lender: OPTION ONE MORTGAGE Current Lender/Servicer: Option One Mortgage Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH.. CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are 'entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OC.CURWITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MOR'1'GAGE ASSISTANCE, YQPMUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. OP171 EXHIBIT A I, CORPORATE OFFICES. 3 ADA _ IRVINE _ CALIFORNIA 92618-2304" P.O. BOk 51'041 .. IRVINE" CALIFORNIA 92619-7041 PHONE 949.784.6100 I 800.326.1500" FAXL,NE 949.784.6026 .~. " .....J.. < I 'lilj e. OPTION ONE Re: Loan No. 169334-0 MORTGAGE CORPORATION CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counselinq agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLlCA~ION FOR MORTGAGE ASSISTANCE - Your mortgage is-in default for the reasons set forth later in this Notice (see following pages-for specific informat~on about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. fi., AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have.met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. OPl7l CORPORATE OFFICES'" 3 ADA" IRVINE'" CALIFORNIA 92618-2304" P.O. BOX 57041'" IRVINE'" CALIFORNIA 92619.7041 PHONE 949.784.6100 I 800.3.26.1500 '" FAXLINE 949.784.6026 I, ." .",'"'; e. Re: Loan No. 169334-0 OPTION ONE MOATGlAGlE CORPORATION ********************************************************************** NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) ********************************************************************** HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE). NATURE OF THE DEFAULT. - The MORTGAGE debt held by the above lender -on _.. your property located at: 313 Lamp Post Lane, Hampden PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE 'MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments: 1 MONTHS @ $ 856.42 2 MONTHS @ $ 856.42 $ 2569.26 (b) Previous late charges; $ 102.76 (c) Other charges; Escrow, Inspection, NSF checks $ (d) Other provisions of the mortgage obligation, if any $ (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE $ 2672.02 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days of the date of this notice BY PAYING THE TOTAL AMO~T PAST DUE TO THE LENDER WHICH IS $2672.02, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and send to: Option One Mortgage Corporation 3 Ada Irvine, Ca. 92618 You can cure any other default by taking the following action within thirty (30) days of the date of this letter. (Do not use if not (applicable. ) OPl72 CO~PORATe OFFices.. 3 ADA" IRVINE. CALIFORNIA 92618.2304" P.O. BOX 57041" IRVINE" CALIFORNIA g2~ng.7041 PHONE 949.784.6100 I 900.328.1500 .. FAXLlNE 949.784.6026 I' ,~ - '~. ~ '"..~t e. OPTION ONE Re: Loan No. 169334-0 MOP'''GAGE COP.POI"l.A.TIQN IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure-- proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. CUring your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately (7) SEVEN Months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. OP173 CORPO...ATE OFFICES" 3 ADA" IRVINE" CALIFORNIA 92618.2304" P.O. BOX 57041 '" IRVINE" CAUFORNIA 92819-7041 PHONE 949.784.6100 /800.326.1500" FAXLINE 949.784.6026 ~_I I...","~ lIIi....J . . e. > OPTION ONE MOFlTGAGE CORPORATION Re: Loan No. 169334-0 HOW TO CONTACT THE LENDER: Name of Lender: Address: Address: Phone Number: Fax Number: Contact Person: Option One Mortgage Corporation 3 Ada Irvine, CA. 92618 800-326-1500, Ext. 8004 949-790-8182 PAUL HOWARD EXT. 5726 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a . lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. /, _. ~/ * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. OP174 CORPORATE OFFICES. 3 AOA. IRVINE. CALIFORNIA 92618.2304. P.O. BOX 57041'" IRVINE'" CALIFORNIA 92619-7041 PHONE 949.784.6100 1800.326.1500'" FAXLINE 949.764.6026 , ~~...~ -"J _.......................__.........-.,........",......"'.-..."""'""...........................,.....-".........~--"'_.....,...,-""'''"""",--""-",,,,,,,,, .' ';~i~t\:;!~i!i .:*!lHVBiliitii;i::;:i!WM!:ji:!iiii!~~!i!!!~i~j;iii~j~iii~~iil!il11~1~~~iiiiiiJ!i~ii!f!iii~fi~~j!ig1ii!i!;ii1! ;.ii;;;!~j::!ntii,,:I'i~,~~i!j~i;;. .;;i~Ji;i~JJ!;:;'!M!."3iii :::;;,,:: ,",-",'.' '-,,',', ..~ ':; :~. }!i\i!!: .;,;.;.: .:.;; ;:;-::~': ",",,'. .. ......;:#1;;:.;([;l11 " i,f~W.ii!~~ii!!llil:Ui!~~!i!~~M!iiil;~I!iii!i!~~i!~I~~%~ii.!~~II~~~l~liil~~~!!iil~~iill!Ji,~!ji~iiiiIM~!;!;!~~i!!;!i~~~;;.~t*:!!i~!iif~;i~~~j!i;!Wk~~i~~i; . ,.. .. -::!\::::f1~i)i:j;,i,:,i.fi:j~;:;.:.:. po_ certmedf" ..-.... H'" ii:~~J[ii~!~~~it!~~i~:iwnl~~!.!!!iJ.i . >~,., , , - , .,j V F. R 1FT CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~ Mark J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES ,bil!iiMi!~ga;o~"4I,illj,jjl''iiE<i"",~&i,lh~,,,j8jiw1I'i~i~!ill~~;;;;'''''''1l"~,~,;,,",-"'~~, ,:,,,,,,,,,;Jt',,,,,",, ~iilIfjf~llr ".'^.oJ''''':''I:j!;1];.l~i,ti 't.: '~Itii;..__ 11Wa_ ."M~;w;,1f"",,",I~_I~ ~ilIlliIIll~' ("::) ~ ~ ~ ~ ~ C1 t- h ~ q L. h. " ~ B ., ? -Ot ',~: , C\ ~,} "",J tv (6) ._,\ ~ ~ -. , ..~,') ft!~ r::; ~.,,'" )>Ci -~ ") ~ ~~.~ ":=.-~\ .. t - . ~ ::-J 'J -'- ~, -t ::2 ,p " -~ 'J' l~i SHERIFF'S RETURN - REGULAR CASE NO: 2000-08279 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK MINNESOTA VS HARRISON CARTER CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HARRISON CARTER the DEFENDANT , at 0013:07 HOURS, on the 7th day of December, 2000 at 313 LAMP POST LANE HAMPDEN CAMP HILL, PA 17011 by handing to CARTER HARRISON a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.06 .00 10.00 .00 36.06 So Answers: /~~ ~f?d{:,e:;~ ~t R. Thomas Kline me this tfE day of 12/08/2000 MARK :~,UD~~!~ Depu y Sherif Sworn and Subscribed to before ~,,~.Ju, / ;:UJ7JU A.D. ~a~~ P othonot.ary I . ,~ - ~ ,--. Ii " ," - .. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 - . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) : NO. 00-8279 Civil Term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESS~ENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest per Complaint From 11/18/00 to 3/5/01 Late charges per Complaint From 12/15/00 to 3/5/01 Escrow payment per Complaint From 12/1/00 to 3/5/01 $100,991. 63 2,913.84 154.14 04 TOTAL $104.059.65 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and 2) that notice h been given in accordance with Rule 237.1, a copy which is attac Q hereto. MARK Mark ren, ESQUIRE Attor ey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDI TED ~ DATE: fIl~~ VI Mol Czto.) J/~ . PRO PROTHY ~ ~~-' =,~,~ - " I ~ I' iIll ~ ""j , . MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) NO. 00-8279 civil Term DATED: TO: January 2, 2001 Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 800-990-9108 NOTIFICACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER US TED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. '.,"-". <".. .10..., ...., MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Associationas Trustee for sAsco Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) . ,I" - ~ ,'t.;,! ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 00-8279 civil Term STATE OF AFFIDAVIT OF NON-MILITARY SERVICE COUNTY OF SS THE UNDERSIGNED being duly sworn, deposes and says that the ;averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant (s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Carter Harrison Over 18 As captioned above Unknown Name: . ~ \ 3'A0.i'l~ T i tl e : rC\e..y.. --(2() <' \ C,1't'tt 1 -fLf Sworn to and subscribed Company: d~ '!:Y. lJotre.n 'l- 8-S-30e.l ~ /-e:3 before me this61l.-ryday - o~ ~cw-U)~- ,2001. DARLENESHEL.LENBE.RGER ~_ ~ NOTARYPUBUCOFNEWJiRSEY Notary ~li c CommluIon bp/rH 1""2llOS ~;,ftIlliiili"' "-"'''1ili:ili;iclii'J,"li!i4-jHllt_''f'll'J~'/0",~lf:J.JU"'IJ';:<"",""~,, 'i"...",,,,o;':',i.I,,,~,,,&i!J~~~' ""'i/lil!l;il:l.& ."'< ~'=~~"<P~~,~,.,,"~"'i...l'i"'~~ '"~- . .r ,. t -p (J ~ (") 0 It- ~ 8 c: 0 <- ~:h -0 ~."'" ::JI: ~'-I- In Cl2 "'"' ~ zC!: :;;0 ~C~ t --- Z""~' n-iF ~ UJ5:" .<:- ~-.:';JrT1 --V -<;,0: 'Oy ?0 ~c '--...) - .'-IU p.::: ~C) :;0. ?~;:B ::;: ~o - "'~',(-.... --e: >c 2m ~ - 0 ~ ~ ~ '-11 j:;! W :u 0 -< '::1:'" 'i'~r- ,]..>:~~j jU;,','1 'i9.P'- " ,;'$:t ,.f " ;',;.':,~u)n].; ~ lI.; U J '0_ .:;',. "".,."",0 ,""""" - -~ O~ i. -,,-"'-- MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) : NO. 00-8279 civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: 313 LAMP POST LANE HAMPDEN, PA 17011 Amount due $104.059.65 Interest From March 6. 2001 2.509.14 to Date of Sale June 6. 2001 Per diem @$26.98 (Costs to be added) $ MARK J. Mark J. dr n, ESQUIRE ATTORNEY FO PLAINTIFF ~~~~lI>'!:1~};?ttfJ~~~1?,l~~~~~'i't>-""'M"-'':JJ'!~',,,*f,,!e'';''''';>'fE!!.~i~~~,~t!:' tU: 'kJtL' ll'rt1liiAl!i!i 'j '",,,, _l',~~~' '~~ili~ ~~~.- ~ 0 0 fP 0 n Q :z -n ~ ~Gv :Ie ""Offi ,.-/ 1t 111[!] ".. i"h:D ~ ~'bQ. "'v "' -:-O0~ ~ ~~! ::0 ~ -L f"" ~~ 08C1b (fJ p. T-1-rn C; () ;=;-c> .;:- _~!JU 0 0' ~ Q ~ \' o () r ~ "'" --,C) ..... (> 20 ;l: :;~- ~ ( ( :;;:: I ( 5>0 - ~}r) ~ - aN1 t t)1J " 1 ~ ~ -c-J =< Ul ).> C.., :0 .., ::: .., ~r -< -...., '. , , , , " ~t ~ , ~ ~ ,~ 1~IJLLL,. II rnrn!l! "' II II I", ,,_,J1,w""_'"'_,,__"'_~, '___"'"' .'., .., ",". ~ "" a " I, MARK J. UDREN &: ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County :'MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) CERTIFICATE TO THE SHERIFF : NO. 00-8279 Civil Term I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: ____A. In Assumpsit (Contract) ____B. In Trespass (Accident) ----1LC. In Mortgage Foreclosure ____D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: -LA. ____B. C. D. E. ____F. An individual Tenants by Entireties Joint Tenants with right of survivorship A partnership Tenants in Common A corporation III. The Defendant(s) is (are): ----1LA. ____B. ____C. Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of pennsylvania If more than one Defendant and ei er A or B above is not applicable, state which Defendant is r s' dent of the Commonwealth of Pennsylvania. Resident: Mark J. Ud n, ESQUIRE Address .D. # as above "" -. ., ,- - ~~ .-""'"~,,~'~. "'!~~~'il:i~ii';icrli:[);\1~:lijiill!M~ltlll'<l&itt~lii\!;;0;jillitoo.~{1"h'~;L""O"; ,,.,:,,,.,, ~;'(."'''''~1!i&;~A~,,*1LUi:Jitiil~,. 1 '""""'--""-- ~~'w iii ,,'L _L,L,,~,.l.LLL ~.~l J 1 ~ ">4,1J",;~,~,,,;=...i ;IJ,m",IJlU,nLDJ;JJL~ o,~'''''_ "'" , -, " , ,,~,', '- , o,~~ , ~;"\<lol>-i~~Ji.~'- -" "~.'-:- ,,, 0 C> 0 C -"1 :;;:: 3: ::;:1 "0 OJ "'" fh-n m,fTl :::0 Z:o , ZS;: '-'".1m ..,- ;~~1,CJ ~2: ...~~ ~CJ :>:>' ~O :::;;: ?) :JJ - ;::;,.,0 -0 ~'-rn :PC - 0 --< :;;:"" c.J'I ~> ~ 50 (.0) -< _<N - - .. "~ t~," , ;,) MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS RIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Camp Rill, PA 17011 : NO. 00-8279 Civil Term Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MARK J. Mark J. ATTORNE f~~~\!k[ll'ii~~l6f_I_-l4;F$l~".;kK'~'~'!',i"i"",,,,::..'l~'I;"'"'i"'<ilr.t..~~&.w-,-.i.ltIS'~II""'''''''''''.~illlf''';;;.'''"'''lil!:'ll1<~~'~~~~ ""~'o"""tJl1'M~~', -~ """, (") 0 0 C -1"1 ;;; :!l: 0--( '""Om > 0i~2 mg:; = z' 'Or-n z. (J) J> J7 coO ~2:, 0. ~;: ~O ::J:>o (5::; ~O 3: ~O >8 - L-rn - ~ Z '-l1 ~ =< eN '.','H,)~,t:""",,...J!1,t*[ U - ~D!'!"L",,~: -'<,,, ",',,",""""',~, "_~ -'1'<, "" . ,'~~, ~ ~-~ ~<=~, ^ ~. ' I" ~~,=_.""""""",;,! MARK J. UDREN " ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 : NO. 00-8279 civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 313 Lamp Post Lane, Hampden Camp Hill, Pa 17011 1. Name and address of Owner(s) or reputed Owner(s) : Name Address CARTER HARRISON 313 LAMP POST LANE, HAMPDEN CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS :II 1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 1,1 , "I. ~'~. ~...J 6., Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. Domestic Relations Section 1 COURTHOUSE SQUARE, CARLISLE, PA 17013 13 N. HANOVER STREET, CARLISLE, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 313 Lamp Post Lane, Hampden Camp Hill, Pa 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn Isification to authorities. MARK . ~y I DATED: March 5, 2001 Mark Attor '~WiS!\iIllffMl~gS<(<;lb~01'" ~q-'_.'k1;-J',i'O~,,(L';,);!l'_;.,,"~.,j,,,g,;.-nA"LiL,:_<.,,,,.,,"_'b,,,"-'.C,',,_! '~~M"'ti"b":,:f::;ili<il,*~~1imli.~l ]Jlj-L~&@1l)~!<<_,,,,;",!S*\i~ll_W_'" c ~ ~"11i~}~.' , (") 0 0 c: ~n ? :x ---I .~ -oce :P" ;J.:o 92fT' :;0 ,,1r~ :r,' "'~"lTl Zr;;~ .t:". ::-.01;::1 63n"~ qb -<L_ r:::O "" -"-'!'-ri ~:O ---::- -n :x DC') Zo 5[11 S>C ~-l ~ U1 ~ - - _.." .~~,~, .. ~ ". . , ,~,I., I., ,J1 I L ~ J. UDREN & ASSOCIATES 'BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-69.00 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff . - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) : NO. 00-8279 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CARTER HARRISON 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Your house (real estate) at 313 Lamp Post Lane, Hampden Camp Hill, Pa 17011 is scheduled to be sold at the Sheriff's Sale on June 6, 2001, at 10: 00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $104,059.65, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THT S SHERIFF'S SAI,E To prevent this Sheriff1s Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (8SG) 482-6900 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) < ..~, ".~ - .. , IJ ,~"~~,-._... ,,,,.I, ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 8S6-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 8S6-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA CUmberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 800-990-9108 ,~:lt bliL ,i .......J I ; _. I ~ .. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Association as Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff - - COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) : NO. 00-8279 civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by itS/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant (s) on the date specified on the said Return Receipt. Copies of the said Notice and .Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: Dated: April 30, 2001 Mark . Udren, Esquire Attorn y for Plaintiff ~ ,c.." , I '"" ]~J' " ._j 1-,- ~ -""'*'1&.;\ - - MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 00-8279 .civil Term v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) DATE: March 29, 2001 . TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): CARTER HARRISON PROPERTY: 313 Lamp Post Lane, Hampden Camp Hill, Pa 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cmnberl,md County Sheriff's Sale on June 6. 2001, at 10:00 AM, in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, CUMBERLAND COUNTY COORTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filihg'of the scl1edule. 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JJ:!:l:: lii m 9! ro 3 ~ fIl 0 g.JJ ~a~~ =~Q,~. om:-- !" ." o o ("):1: ",0 !!15. <g~ 00if9 ~~~~ 0'1J~13l ~ g ~:g 01[:5:3 ~ 5' ~.-g. 5' ~ :-:-!:2. '" i>> CD 0' C" OJ ~ 0 , " g "" g -a~ ". m< 000 (ire ~. <" 00 _0 0" 00 0. ~~ )> Q,3:~ a:a=\a ~!!1.'Il !!!..ro3 00"" 0-", ~.~~ fIl=(1I o::r::;; ~~. (ir~lii croc. ","~ " JJ:g: (11,;" 3 0 ~:jE. o ." m m - ,. Norwest Bank Minnesota, National Association as Trustee for SASCO Mortgage Loan VS Carter Harrison ,-~:I ' I, <- ~lll<c~i In the Court of Co=on Pleas of Cumberland County, Pennsylvania No.2000-8279 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Law Library County Mileage Levy Certified Mail Surcharge Postpone Sale Patriot News Law Journal Share of Bills Sworn and subscribed to before me This ,"'" daYOf~ 2001, A.D. ~-,-,O)n'IJL-A~~ TO onotary !i" 30.00 204.94 15.00 15.00 .50 1.00 8.06 15.00 1.72 20.00 20.00 272.28 307.25 25.09 935.84 paid by attorney 6-4-01 So~~Y" ~ r ~;.e;.""<-r/~ R. Thomas Kline, Sheriff BY (~~ . rJ0 ,11/ t eJI'--31" ~o:3 \~ilJ . '" - ""...;",1:_: 1'. .... ~ MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 1701l : NO. 00-8279 Civil Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 3l29.1 Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 313 Lamp Post Lane, Hampden Camp Hill, Pa l70ll 1. Name and address of Owner(s) or reputed Owner(s) : Name Address CARTER HARRISON 313 LAMP POST LANE, HAMPDEN CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE , ~I " .-...~~~I,.' ,,~ . ,. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQUARE, CARLISLE, PA 17013 13 N. HANOVER STREET, CARLISLE, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every knowledge who has any interest the sale: Name other person of whom the plaintiff has in the property which may be affected by Address Tenants/Occupants 313 Lamp Post Lane, Hampden Camp Hill, Pa 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn sification to authorities. MARK dren, ESQ. for Plaintiff DATED: March 5, 2001 Mark tb Attor V y I J ., t,,-~", ~ '. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Norwest Bank Minnesota, National Associationas Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 92619-7038 COURT OF COMMON PLEAS CIVIL DIVISION : Cumberland County : MORTGAGE FORECLOSURE Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 : NO. 00-8279 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CARTER HARRISON 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Your house (real estate) at 313 Lamp Post Lane, Hampden Camp Hill, Pa 17011 is scheduled to be sold at the Sheriff's Sale on June 6, 2001, at 10: 00 AM in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA to enforce the court judgment of $104,059.65, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed~ the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffls Sale, you must take immediate action- 1. The s."le will be cancelled if you pay to .the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (SS6) 482-6900 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the .sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . "-='$ . .. ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 8S6-~82-6900. . 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 8S6-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. S. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUmberland County Bar Association 2 Liberty Avenue Carlisle, pa 17013-3387 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FlLADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa 17013-3387 800-990-9108 . i . "I.,. 1-- """""'~ ~~ . ~ ALL THAT CERTAIN PIECE OR PARCEL OF LAND, WITH IMPROVEMENTS THEREON ERECTED, SITUATE IN THE TOWNSHIP OF Hl\MPDEN, COUNTY OF CUMBERLAND, STATE OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS, TO WIT: BEGUlNING AT A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POsr- LANE AT THE DIVIDING LINE BETWEEN LOT NOS. 9 AND 10, BLOCK "H' OF THE HEREINAFTER MENTIONED PLAN, WHICH POINT IS 627.23 FEET IN A NORTHWESTERLY DIRECTION FROM THE SOUTHWESTERLY CORNER OF CARRIAGE HOUSE DRIVE AND LAMP POST LANE OF THE PLAN; THENCE BY SAID DIVIDING LINE SOUTH 35 DEGREES, 10 MINUTES WEST 113.27 FEET TO A POINT AT THE LINE OF LOT 13, BLOCK "H" OF THE PLAN; THENCE ALONG LOTS NOS. 13 AND 12, NORTH 59 DEGREES, 30 MINUTES WEST 100.33 FEET TO THE DIVIDING LINE BETWEEN LOTS NO.S 10 AND 11, BLOCK "Il" OF THE PLAN; THENCE BY SAID DIVIDING LINE NORTH 35 DEGREES, 10 MINUTES EAST 121.43 FEET TO A POINT ON THE SOUTHWESTERLY SIDE OF LAMP POST LANE; THENCE BY SAME SOUTH 54 DEGREES, 50 MINUTES EAST 100 FEET TO A POINT AT THE DIVIDING LINE IlETWEEN LOTS NO.9 AND 10, BLOCK "H" OF THE PLAN, THE PLACE OF BEGINNING. BEING ALL OF LOT NO. 10, BLOCK "H", PLAN 4 011' PINE BROOK AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 15, PAGE 41. BEING KNOWN AS 313 LAMP POST LANE, HAMPDEN, PA17011 PROPERTY ID# 10-20-1848-108 TITLE TO SAID PREMISES IS VESTED IN CARTER HARRISON, SINGLE MAN BY DEED . FROM CARTER HARRISON AND GUO HARRISON, HUSBAND AND WIFE DATED 4/19/1999 AND RECORDED 5/26/1999 INDEED BOOK 200 PAGE 211 . i_ ., ,. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUM~ERLAND) NO. 00-8279 CIVIL ~ TERM CIVIL ACTION - LAW - TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due No:r:west Bank Minnesota, National Association as 'I'rtlRt:ee for BASCO Mortqaqe Loan from Carter Harrison, 313 Lamp Post Lane, Hampden, Camp Hill, PA 17011 PLAINTIFF(S) DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description ;..to. ,_ ," (2) You are also directed io attach the property of the defendant(s) not levied upon,i[1the possession of :.' - ."...."~-.._-...".".." :}1 \i'~n.."~. ~ . ~ , . /, i(!,f '_ f' ~1n"1 ."',~~ -ti "'~'''''..-".",,;t , '- ",~.,.', " i Ii " . .!t"l'V]I(;.,'" . .. ".,. "'f fJf'l~ r ."'" "'r1f'llt"'~ GARNISHEE(S) as follows: "i/irf(<~ . \'W1:'t:; I~'dr ....__,..'''A.....~.,~''.. and to notffy the garnishee(s) t~t: (a) an allachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from deliverin'!l:'~~~hIfri_f.nt(s) or otherwise disposing thereof; , . (3) If property of the defendant(s) not levied upon an subject to attachmentis foundjpthe possession of anyone other than a named garnishee, you are directed to notify him/her that he/she haS been added as a gil'rnishee and is enjoined as above stated. Amount Due $104,059.65 from 3/6/01 to 6/6/0j per diem Interest @$26.98 $2,5Qg 14 Atty's Comm % Atty Paid $\(lR Of) Plaintiff Paid L.L. Due Prothy Other Costs $,50 S1.00 Date: M"rch 14, 2001 Curtis R. Long Prothonotary, Civil Division hy' L2o~P - P /7((J?/U'rf'~ .. . Deputy REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 N. Kings Highway,. suite 500 Cherry Hill, NJ 08034 Attorney lor: Plaintiff Telephone: 856-482-6900 Supreme Court ID No. 04302 " ~"~-lJ~r' j'- 'C"" '. "."'J! ,;'-"'i", '1':'-''''"'''' 1lll1li;1__ .,",,' ". .",c ~~....~_~._1i'.'.'..'...'. ...... _ _~iil1trMWt~~~kIt..,.""-,",,,"'~" .~ @g c:::::::t ~ ~ (~::) '",'.""~"~" , " . . , REAL ESTATE S"L." ... R t '~D. J5 J{l rr7 wvr-h- I ~ ;;l. 00 I tne snantt levted upon the C1e!"enu,\I;.:. 1nt8f8St In the reat.property situated In 1Id./I^P&J{--rtfWlU)Jti~ ~ r.n&y. Pa., known and numb8l8d 88: 3/ 31aPLPf~ I.~ t()../YLf.> ~ and more fully described on Exblblt "A" flied with this writ lIIdby _reference Incorporated h8I8In. IlIIr. f~~/5,:U>OJ By: i!r:::;;ll~ .. c~~:.6 "",\1,," ,JCI "\"",, """.,,:'" 'I ,\Y"~ ~~'t. ~ ~1. ~\ S\ ,,'J \~. ~ ..<,;~\~~O I}l ,~\l }.\.""",c'll"" ~~\\\:> - .,~=,,,,,", " . _0 , ~ MARK J. UDREN & ASSOCIATES BY: MarkJ. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Norwest Bank Minnesota, National Association as Trustee for SASCO Mortgage Loan Trust 1999-BC4 P.O. Box 57038 Irvine, Ca 926l9-7038 Plaintiff v. Carter Harrison 313 Lamp Post Lane Hampden Camp Hill, PA 17011 Defendant(s) ,. I, ~, " ""- '".'~:: I, ! ATTORNEY FOR PLAINTIFF - - COURT OF COMMON PLEAS : CIVIL DIVISION : Cumberland County : NO. 00-8279 civil Term PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: July 2. 2001 /lZftkiL tId~ Mark J. Udren, Esquire --. Mark J. Udren & Associates Attorney for Plaintiff